Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

September 4, 1991

Mr. Paul V. Williams
Health and Safety Specialist
General Dynamics
Land Systems Division
Post Office Box 2072
Warren, Michigan 48090-2072

Dear Mr. Williams:

This is in response to your letter requesting clarification of some issues related to a Standard Threshold Shift (STS) in hearing level. Before we answer your questions we wish to inform you that the Occupational Safety and Health Administration (OSHA) is currently not enforcing the recording of hearing loss on OSHA Form 200 unless the shift from the original baseline audiogram at frequencies 2,000, 3,000, and 4,000 Hz averages 25 dB or greater in either ear.

1. If an audiogram shows a hearing loss that is recordable on OSHA Form 200, the date must be entered in column (B) is the date the employee was tested. If a retest performed within 30 calendar days of the initial test shows the hearing loss is not recordable on OSHA Form 200, the original entry may be deleted by drawing a line through it.

2. A retest audiogram may not be substituted for an initial audiogram unless it is obtained within thirty calendar days of the date of initial audiogram regardless of the fact that an outside evaluating concern is used.

3. The thirty day retest time limit was adopted to enable employees to learn about their state of hearing as soon as practicable.

We appreciate the opportunity to clarify these matters for you.


Patricia K. Clark, Director
Directorate of Compliance Programs

June 4, 1991

Ms. Patricia Clark
Department of Labor/OSHA
Directorate of Compliance
200 Constitution Avenue NW
Washington, DC 20210

Subject: Clarification of 1910.95 Standard Contents

Dear Ms. Clark:

Recently a couple questions arose within my company that require clarification from your office on the Occupational Noise Exposure Standard contents. It would be appreciated if you could advise me of the following so that we can ensure compliance with these regulations.

1. What date would be entered in column (B) on the OSHA 200 Form if a Standard Threshold Shift (STS) is indicated on the annual exam? If you use an outside audiologist to evaluate your audiograms and you perform the 30 day re-test when STSs are indicated, would this have any effect on the "initial diagnosis" OSHA 200 Form entry date?

2. With regard to the 30 day retest [(sub paragraph (?) (ii)], are work days or calendar days used for the count? Also, what date would be used to "start the clock" if you use an outside evaluating concern -- the date of the test or the date of notification of the STS?

3. What is so magical about the 30 day time frame for the STS re-test? If the re-test was performed 45, 60 or even 120 days afterward and verified that an STS really did not occur, wouldn't this still be valid? I would like to request that the rationale for this be provided.

Thank you for your review and provision of a written response to the above questions. If you have any questions about the above, please feel free to contact me at (313) 825-4501.

Paul V. Williams
Health and Safety Specialist